EI has been providing SPCC plans and related services for 20 years and is eminently qualified in this area. Our specialists have written papers, presented at conferences, and participated in national seminars on the topic. We have provided services to utilities, municipalities, major industries, and commercial property owners. With that, EI’s professionals have the background and experience to provide any service associated with SPCC Rule compliance, including:
- SPCC Development
- Facility Response Plan (FRP) development per 40 CFR 112.20
- Compliance Reviews
- Tank Inspections per the STI Standard
- Expert Consultation and Opinions
History of SPCC
The Federal Government first developed rules in 1974 regulating above ground oil storage tanks. The Exxon Valdez accident prompted the United States Congress to pass the Oil Pollution Control Act of 1990. Following the Ashland oil spill in Floreffe, Pennsylvania, where 750,000 gallons of oil discharged into the Monongahela River, the EPA, not waiting for Congress, began making significant changes to the “Spill Prevention, Control and Counter-Measure (SPCC) Rule.”
The major 2010 changes to the SPCC Rule include the following:
- Broadening of the definition of “oil.”
- Including oil-filled operational equipment, e.g., transformers, lube systems.
- Including requirements for loading/unloading areas and racks.
- Clarification on secondary containment requirements.
- Allowing exemptions for “Qualified Facilities.”
- Required formal inspections and testing as prescribed by API, STI, or others.
The Steel Tank Institute (STI) wrote the standard for testing shop-fabricated tanks. EI’s tank inspectors are STI-Certified and are ready to assist with storage tank inspection and testing compliance
In addition to SPCC requirements, 40 CFR 112 also contains regulations for the applicability, development, and implementation of Facility Response Plans (FRP) for facilities that pose a particular oil spill risk, e.g., a total storage capacity of 1,000,000 gallons. EI is well versed in this area as well having prepared and updated dozens of FRPs.
EI’s SPCC experts can answer any SPCC questions or provide the required services to ensure your compliance with the rules.
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Banks, Borrowers and Climate Change: How Disclosure of GHG Emissions Will Impact the Lending Process for Publicly Traded Corporations
The EI Group, in collaboration with Environmental Risk Innovations (ERI), recently launched a joint blog series which outlines the impact of the SEC’s proposed climate disclosure rule, which will require all publicly traded corporations, including banks, to disclose their direct and indirect GHG emissions. For manufacturers, carbon emissions are generally those resulting from the products they produce (direct), from the production of energy used in their production process (indirect) and their supply chain (indirect). For publicly traded banks, this concept is slightly more abstract.